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MEMORANDUM
TO:
Jim
Eddinger,
EPA/
ESD
FROM:
Roy
Oommen,
ERG/
MOR
DATE:
July
7,
2003
SUBJECT:
Summary
of
May
22,
2003
Boiler
Meeting
with
ACC
A
meeting
between
the
U.
S.
Environmental
Protection
Agency
(
EPA)
and
the
American
Chemistry
Council
(
ACC)
was
held
on
May
22,
2003
in
Research
Triangle
Park,
NC.
The
purpose
of
the
meeting
was
to
discuss
ACC's
comments
on
the
proposed
Stationary
Combustion
Turbine,
Reciprocating
Engine,
and
Industrial,
Institutional,
and
Commercial
Boiler
and
Process
Heater
National
Emission
Standards
for
Hazardous
Air
Pollutants
(
NESHAP).

Meeting
attendees
included
representatives
of
the
OAQPS
Emission
Standards
Division
of
the
Environmental
Protection
Agency
(
EPA),
ACC,
and
various
chemical
companies.
A
complete
list
of
attendees
(
with
their
affiliation)
is
included
as
attachment
1.

Members
of
ACC
discussed
comments
submitted
on
the
Boiler
NESHAP.
The
agenda
for
the
meeting
is
provided
in
attachment
2.
2
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Attachment
1
Meeting
Attendance
List
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Meeting
Attendance
List
Mark
Allen
BSF
Tim
Backstrom
EPA,
Office
of
General
Council
James
Connolly
Hoffmann­
La
Roche
John
deRuyter
Dupont
John
Dege
Dupont
Jim
Eddinger
U.
S.
Environmental
Protection
Agency
OAQPS
Ron
Huffman
Bayer
Liz
McMeekin
PPG
Bob
Morehouse
ExxonMobil
Roy
Oommen
ERG
Jaime
Pagan
U.
S.
Environmental
Protection
Agency
OAQPS
Sims
Roy
U.
S.
Environmental
Protection
Agency
OAQPS
Brad
Shanks
American
Chemistry
Council
Ron
Shipley
American
Chemistry
Council
Melanie
Taylor
AGTI
Bob
Wayland
U.
S.
Environmental
Protection
Agency
OAQPS
Attachment
2
Meeting
Agenda
Combustion
MACT
Meeting
Outline
May
22,
2003
1:
00
 
3:
00
EDT
General
(
15
minutes)

Introductions
Response
to
challenges
of
EPA
MACT
process
Broad
affected
source
definition
Turbine
MACT
(
40
minutes)

Applicability
­
Definition
of
stationary
combustion
turbine
and
system
­
Emergency
turbine
definition
­
Limited
use
turbine
definition
­
1
MW
exemption
Floors
­
Existing
lean
premix
turbine
floor
determination:
"
no
control"
vs
proposed
emission
standard
­
"
No
control"
determination
for
existing
diffusion
flame
turbines
Compliance
­
CO
emission
reduction
requirement:
90%
vs
95%
­
Alternate
to
the
CO
reduction
requirement:
establish
a
CO
emission
concentration
limit
­
Feasibility
of
using
"
add­
on"
control
technology
to
attain
an
emission
limit
­
No
currently
validated
measurement
method
for
formaldehyde
emission
limit
­
CO
emission
averaging
time:
24
vs
4
hours
Risk:
GTA
delisting
petition
for
gas­
fired
turbines
Boiler/
Process
Heater
MACT
(
50
minutes)

Applicability
Subcategories
­
Support
listed
exemptions
­
Deminimis
applicability
­
Distillate
oil
fired
exemption
needed
­
Gas
curtailment
consideration
Flexibility
Risk­
based
approach
for
HCl
Bubbling
compliance
alternative
Floors/
Emission
Limits
­
Support
fuel
switching
as
not
an
appropriate
Floor
or
BTF
control
basis
­
Control
technology
approach
is
appropriate
­
No
control
as
a
Floor
­
Limits
must
be
achievable
by
all
sources
­
Mercury
emission
limits
­
Methodology
used
to
establish
the
Floor
­
Fuel
variability
Work
Practice
Standards
­
CO
approach
for
new
sources
should
be
modified
­
CO
should
be
a
trigger
for
corrective
action,
not
a
limit
Compliance
Operating
parameters
established
during
initial
compliance
test
­
Opacity
­
Other
parameters
­
Fuel
quality
approach
­
Performance
test
timing,
frequency,
flexibility
Reporting
and
Recordkeeping
R/
R
for
units
with
no
control
requirements
Engine
MACT
(
15
minutes)

Applicability
­
Clarification
and
expansion
of
the
emergency
power/
limited
use
RICE
definition
­
Exemption
for
engines
<
500
HP;
inclusion
in
affected
source;
650
HP
vs
500
HP
Floors
­
"
No
control"
determination
for
existing
2SLB,
4SLB
and
CI
RICE
­
Existing
4SRB
floor
reassessment
Compliance
­
Equipment/
work
practice
standards
vs
CO
and
formaldehyde
emission
limitations
­
Formaldehyde
as
HAP
surrogate
­
Deletion
of
operating
limitations
­
Alternate
to
the
CO
reduction
requirement:
establish
a
CO
emission
concentration
limit
­
Clarification
on
no
SSMP
requirement
­
Feasibility
of
control
technology
